Have been reading with interest the posts about recent exams and UDAAP standards as they are being applied to deposits products. Has anyone encountered any exam flak about age advantaged accounts like a 50 plus account or waiving fees for certain age groups (62 plus or students (18-23))?

Not unless they also involve credit products or the deposit products are not delivered as advertised.

We have not encountered anything yet, but there have been rumblings at a couple of compliance seminars I have attended that this issue is coming.

Is Overdraft Protection considered a "Credit Product?" I have read a couple of recent articles that has the FDIC citing banks for having a 50 or 55 account with ODP as age discrimination given its not a 62 account.

Overdrafts are credit under Regulation B.

So if I have a "Bank 50" account with say lower fees than our "Standard Bank" account that has ODP tied to it - then I am discriminating based on age because the cut-off its not 62?

bump
So if I have a "Bank 50" account with say lower fees than our "Standard Bank" account that has ODP tied to it - then I am discriminating based on age because the cut-off its not 62?

That is the gist of the argument.

thanks JB - I am struggling to connect the dots...

Is overdraft protection differences the only thing that could cause examiners to view an account for age 50+ as discrimination? Like a higher courtesy overdraft limit.
What if this type of account has other age related advantages that other account types don't have like free check images with statements and free cashiers checks. Would that be considered discrimination?

The freebie would need to be related to loans to trigger the ECOA age limit. A free appraisal for anyone 50+ will be a problem, as an example other than overdraft benefits. (This has been cited at banks in 2011.)